Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-002.
Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken:
1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies.
2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance.
3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing.
4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner.
5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance.
The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements.
By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-002.
Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken:
1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies.
2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance.
3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing.
4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner.
5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance.
The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements.
By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-002 – N. Special Tests and Provisions – Federal Perkins Loan Program Recordkeeping and Record Retention
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.038)
Criteria or Specific Requirement – Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period.
An institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using a master promissory note for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party servicer is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third party servicer’s most recent Title IV compliance audit.
When an institution uses a third-party servicer for its Federal Perkins Loan Program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Certain Federal Perkins Loan Program records selected for testing were missing a signed master promissory note, missing repayment schedules, missing documentation for the first disbursement, missing documentation for the last payment, or missing other documentation.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with the Federal Perkins Loan Program recordkeeping and record retention requirements.
Questioned Costs – None.
Context – For 1 of 40 Federal Perkins Loan Program records selected for testing, we noted that 1 record was missing a signed master promissory note and a repayment schedule.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-005.
Recommendation – We recommend that the University enhance its procedures and internal controls related to Federal Perkins Loan Program recordkeeping and record retention.
Views of Responsible Officials – The University acknowledges this finding and during its liquidation of the Federal Perkins Loan Program completed the buyback of certain loans for which the University was not able to provide adequate documentation to assign these loans to the Department of Education.
Subsequent to June 30, 2024, the University has completed the following steps in the closeout of its Federal Perkins Loan Program:
1. Notified the Department of Education of the intent to liquidate.
2. Assigned outstanding Perkins loans to the Department of Education and updated NSLDS throughout the assignment process.
3. Purchased loans not qualifying for assignment and submitted cash on hand (Intent and Closeout Form Phase 3 in COD)
4. Remitted the federal share to the Department
5. Submitted final FISAP data (Intent to Closeout Form Phase 4 in COD)
The final remaining step for the University to complete closeout of its Federal Perkins Loan Program is to submit a Perkins closeout audit to the Department. This will be submitted as part of the Single Audit for the year ended June 30, 2025, which is due March 31, 2026.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-002.
Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken:
1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies.
2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance.
3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing.
4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner.
5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance.
The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements.
By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-002.
Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken:
1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies.
2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance.
3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing.
4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner.
5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance.
The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements.
By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-004 – E. Eligibility – Over award of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.268)
Criteria or Specific Requirement – Student financial assistance awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A student was awarded total aid in excess of the student’s cost of attendance.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A student received total aid in excess of the student’s cost of attendance resulting in the University not being in compliance with eligibility requirements.
Questioned Costs – Known questioned costs were $2,742 which were specific to 1 of 25 student selected for eligibility testing who received total aid in excess of the student’s cost of attendance.
Context – For 1 of 25 students selected for eligibility testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to award of student financial assistance awards to prevent total aid from being award in excess of the student’s cost of attendance.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken:
1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coordination among various programs and between federal and non-federal aid sources to ensure that total aid awarded does not exceed a student’s financial need or cost of attendance. This aligns with federal regulations requiring institutions to prevent over awards by adjusting aid packages accordingly.
2. Implement Advanced Technological Solutions: The University will collaborate with technology support teams to develop data platforms and scripts that monitor and control award amounts, ensuring they do not surpass students’ cost of attendance. This proactive approach will aid in preventing future over award situations.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal financial aid regulations and to uphold the integrity of its financial aid programs.
By implementing these measures, the University aims to rectify the identified over award issue and prevent similar occurrences in the future, thereby maintaining compliance with Title IV funding requirements.
Finding 2024-005 – L. Reporting – Financial Reporting
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.268)
Criteria or Specific Requirement – Institutions submit Federal Direct Student Loans, Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education Grants, and Iraq and Afghanistan Service Grant origination records and disbursement records to the Common Origination and Disbursement (“COD”) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 86, Number 119, June 24, 2021). The disbursement record reports the actual disbursement date and the amount of the disbursement. U.S. Department of Education processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data U.S. Department of Education has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – For a disbursement of Federal Direct Student Loans program funds, the University did not submit the origination and disbursement records to the COD system within the required timeframes.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University did not submit the origination and disbursement records to the COD system within the required timeframes resulting in the University not being in compliance with the financial reporting requirements.
Questioned Costs – None.
Context – For 1 of 25 students selected for COD reporting testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the submission of origination and disbursement records to the COD system.
Views of Responsible Officials – The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken:
1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and internal controls related to the submission of origination and disbursement records to the COD system. This includes implementing stricter monitoring mechanisms to ensure all records are submitted within the required timeframes.
2. Implement Advanced Technology Solutions: To improve the efficiency and accuracy of financial reporting, the University will adopt advanced technology solutions. These tools will facilitate timely and accurate submission of required data to the COD system.
The newly established internal audit team will oversee the implementation and management of these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal origination and disbursement requirements.
By taking these steps, the University aims to rectify the identified deficiency and prevent future occurrences, thereby maintaining the integrity of its financial reporting processes.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management
Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various)
Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)).
2 CFR sections 200.313(c) and (e) requires that property records be maintained that include 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 (collectively, the “Required Equipment Information”).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with equipment management requirements.
Questioned Costs – None.
Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved.
For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above.
Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will:
1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function.
2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements.
3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems.
The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-002.
Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken:
1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies.
2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance.
3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing.
4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner.
5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance.
The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements.
By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-002.
Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken:
1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies.
2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance.
3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing.
4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner.
5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance.
The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements.
By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-002 – N. Special Tests and Provisions – Federal Perkins Loan Program Recordkeeping and Record Retention
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.038)
Criteria or Specific Requirement – Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period.
An institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using a master promissory note for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party servicer is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third party servicer’s most recent Title IV compliance audit.
When an institution uses a third-party servicer for its Federal Perkins Loan Program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – Certain Federal Perkins Loan Program records selected for testing were missing a signed master promissory note, missing repayment schedules, missing documentation for the first disbursement, missing documentation for the last payment, or missing other documentation.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University was not in compliance with the Federal Perkins Loan Program recordkeeping and record retention requirements.
Questioned Costs – None.
Context – For 1 of 40 Federal Perkins Loan Program records selected for testing, we noted that 1 record was missing a signed master promissory note and a repayment schedule.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-005.
Recommendation – We recommend that the University enhance its procedures and internal controls related to Federal Perkins Loan Program recordkeeping and record retention.
Views of Responsible Officials – The University acknowledges this finding and during its liquidation of the Federal Perkins Loan Program completed the buyback of certain loans for which the University was not able to provide adequate documentation to assign these loans to the Department of Education.
Subsequent to June 30, 2024, the University has completed the following steps in the closeout of its Federal Perkins Loan Program:
1. Notified the Department of Education of the intent to liquidate.
2. Assigned outstanding Perkins loans to the Department of Education and updated NSLDS throughout the assignment process.
3. Purchased loans not qualifying for assignment and submitted cash on hand (Intent and Closeout Form Phase 3 in COD)
4. Remitted the federal share to the Department
5. Submitted final FISAP data (Intent to Closeout Form Phase 4 in COD)
The final remaining step for the University to complete closeout of its Federal Perkins Loan Program is to submit a Perkins closeout audit to the Department. This will be submitted as part of the Single Audit for the year ended June 30, 2025, which is due March 31, 2026.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-002.
Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken:
1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies.
2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance.
3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing.
4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner.
5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance.
The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements.
By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268)
Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-002.
Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken:
1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies.
2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance.
3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing.
4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner.
5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance.
The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements.
By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.
Finding 2024-004 – E. Eligibility – Over award of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.268)
Criteria or Specific Requirement – Student financial assistance awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A student was awarded total aid in excess of the student’s cost of attendance.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A student received total aid in excess of the student’s cost of attendance resulting in the University not being in compliance with eligibility requirements.
Questioned Costs – Known questioned costs were $2,742 which were specific to 1 of 25 student selected for eligibility testing who received total aid in excess of the student’s cost of attendance.
Context – For 1 of 25 students selected for eligibility testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to award of student financial assistance awards to prevent total aid from being award in excess of the student’s cost of attendance.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken:
1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coordination among various programs and between federal and non-federal aid sources to ensure that total aid awarded does not exceed a student’s financial need or cost of attendance. This aligns with federal regulations requiring institutions to prevent over awards by adjusting aid packages accordingly.
2. Implement Advanced Technological Solutions: The University will collaborate with technology support teams to develop data platforms and scripts that monitor and control award amounts, ensuring they do not surpass students’ cost of attendance. This proactive approach will aid in preventing future over award situations.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal financial aid regulations and to uphold the integrity of its financial aid programs.
By implementing these measures, the University aims to rectify the identified over award issue and prevent similar occurrences in the future, thereby maintaining compliance with Title IV funding requirements.
Finding 2024-005 – L. Reporting – Financial Reporting
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.268)
Criteria or Specific Requirement – Institutions submit Federal Direct Student Loans, Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education Grants, and Iraq and Afghanistan Service Grant origination records and disbursement records to the Common Origination and Disbursement (“COD”) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 86, Number 119, June 24, 2021). The disbursement record reports the actual disbursement date and the amount of the disbursement. U.S. Department of Education processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data U.S. Department of Education has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – For a disbursement of Federal Direct Student Loans program funds, the University did not submit the origination and disbursement records to the COD system within the required timeframes.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – The University did not submit the origination and disbursement records to the COD system within the required timeframes resulting in the University not being in compliance with the financial reporting requirements.
Questioned Costs – None.
Context – For 1 of 25 students selected for COD reporting testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the submission of origination and disbursement records to the COD system.
Views of Responsible Officials – The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken:
1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and internal controls related to the submission of origination and disbursement records to the COD system. This includes implementing stricter monitoring mechanisms to ensure all records are submitted within the required timeframes.
2. Implement Advanced Technology Solutions: To improve the efficiency and accuracy of financial reporting, the University will adopt advanced technology solutions. These tools will facilitate timely and accurate submission of required data to the COD system.
The newly established internal audit team will oversee the implementation and management of these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal origination and disbursement requirements.
By taking these steps, the University aims to rectify the identified deficiency and prevent future occurrences, thereby maintaining the integrity of its financial reporting processes.
Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds
Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379)
Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – A return of Title IV funds for a student was not completed within the required time frames.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements.
Questioned Costs – None.
Context – For 1 of 3 students selected for return of Title IV funds testing.
Indication of Repeat Finding - No similar finding noted in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames.
Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken:
1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies.
2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines.
3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance.
The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds.
By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.