2022 004 Reporting U.S. Department of Education: Student Financial Assistance Cluster ? Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Award Numbers and Years: P063P211813 (7/1/21 ? 6/30/22) and P268K221813 (7/1/21 ? 6/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: N/A Finding Type: Material Weakness Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the 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 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED 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. 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, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that the Pell reporting requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University has a process in place to submit the required information to COD on a weekly basis. For the 40 selections we tested, there were no compliance exceptions noted. However, the University did not properly maintain evidence that they had a control in place to review the ED acknowledgement reports and to ensure disbursement data was reported within the 15 calendar day requirement. The University?s policies and procedures to ensure compliance with the above requirements did not include procedures to properly maintain for the existence of a control or that the control was being performed. Cause The University did not have a process in place to maintain the documentation regarding the existence or performance of the control. Effect The University does not meet the Federal requirements to maintain documentation of its internal controls over the 15 calendar day reporting compliance requirement. Questioned Costs None Recommendation We recommend the University ensure that internal controls are in place surrounding the 15 calendar day reporting process related to Pell and Direct Loan reporting in relation to the Student Financial Assistance Cluster and are performed as designed and documentation is maintained.
2022 004 Reporting U.S. Department of Education: Student Financial Assistance Cluster ? Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Award Numbers and Years: P063P211813 (7/1/21 ? 6/30/22) and P268K221813 (7/1/21 ? 6/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: N/A Finding Type: Material Weakness Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the 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 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED 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. 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, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that the Pell reporting requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University has a process in place to submit the required information to COD on a weekly basis. For the 40 selections we tested, there were no compliance exceptions noted. However, the University did not properly maintain evidence that they had a control in place to review the ED acknowledgement reports and to ensure disbursement data was reported within the 15 calendar day requirement. The University?s policies and procedures to ensure compliance with the above requirements did not include procedures to properly maintain for the existence of a control or that the control was being performed. Cause The University did not have a process in place to maintain the documentation regarding the existence or performance of the control. Effect The University does not meet the Federal requirements to maintain documentation of its internal controls over the 15 calendar day reporting compliance requirement. Questioned Costs None Recommendation We recommend the University ensure that internal controls are in place surrounding the 15 calendar day reporting process related to Pell and Direct Loan reporting in relation to the Student Financial Assistance Cluster and are performed as designed and documentation is maintained.
2022 002 Reporting U.S. Department of Education: Education Stabilization Fund ? Higher Education Emergency Relief Fund (HEERF) Student Aid Portion (ALN 84.425E) Federal Award Numbers and Years: P425F200214 (4/21/20 ? 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2021-003 Finding Type: Material Weakness and Material Noncompliance Criteria The Department of Education requires that institutions who received the Section 18004(a)(1) Student Aid Portion of higher education emergency relief funding (HEERF) to publicly post certain information on their website every calendar quarter. The report must be updated no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context During 2022, the University did not update their website each quarter. The University only updated its website for the quarter ending June 30, 2022. In addition, the University could not provide evidence that the information for the quarter ended June 30, 2022 was updated on the website timely or appropriately reviewed prior to posting. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that information displayed on the website was reported timely, complete and accurate. Cause The University did not have policies and procedures in place to ensure that the website was appropriately updated on a quarterly basis. In addition, the University did not maintain documentation that the information was reported timely and was properly reviewed by someone other than the preparer with knowledge of the subject matter. Effect The information displayed on the University?s website was not current throughout fiscal year 2022. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies and procedures over the website reporting in relation to the Education Stabilization Fund program. We also recommend that the University ensure that internal controls in place surrounding the review of the website reporting are performed as designed and that documentation supporting the amounts reported is adequately maintained, along with evidence that the information was adequately reviewed by someone other than the preparer with knowledge of the subject matter.
2022 003 Cash Management U.S. Department of Education: Education Stabilization Fund ? Higher Education Emergency Relief Fund (HEERF) Minority Serving Institutions (ALN 84.425L) Federal Award Numbers and Years: P425L200021 (4/21/20 ? 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: N/A Finding Type: Material Weakness and Material Noncompliance Criteria For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that cash management requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University had one HEERF drawdown during fiscal year 2022. The drawdown occurred on August 5, 2021, however, the funds were spent during the timeframe of September 23, 2021 through February 10, 2022. Therefore, the University did not spend the drawdown within the required timeframe. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the drawn down funds were spent within the applicable guidelines. Cause The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that funds were spent timely in accordance with the compliance requirement. Effect The University held onto unspent HEERF funds outside of the allowable timeframe, and may have earned unallowable interest on its bank account that should be returned to the awarding agency. Questioned Costs As amounts were ultimately expended for allowable purposes, questioned costs would be limited to interest earned on amounts held outside the allowable timeframe. Recommendation We recommend that the University strengthen its policies and procedures over the cash management process in relation to the Education Stabilization Fund program. We also recommend that the University ensure that internal controls in place surrounding the cash management process are performed as designed.
2022-001 ? Level of Effort U.S. Department of Education: Passed through State of New Jersey, Department of Education: Higher Education Institutional Aid - Proyecto Stem: Evidence-Based Approaches to STEM Enrollment, Retention, and Graduation at Urban Public Hispanic-Serving Institution (ALN 84.031C) Federal Award Numbers and Years: P031C160155 (7/1/2021 ? 6/30/2022) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: None Finding Type: Significant Deficiency and Noncompliance Criteria: The specific requirements for matching, level of effort, and earmarking are unique to each Federal program and are found in the statutes, regulations, and the terms and conditions of awards pertaining to the program. Level of effort includes requirements for (a) a specified level of service to be provide from period to period, (b) a specified level of expenditures from non-Federal or Federal sources for specified activities to be maintained from period to period, and (c) Federal funds to supplement and not supplant non-Federal funding of services. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The grant as the following level of effort requirements for key personnel in the award notification letter: We tested the level of effort requirement for the Project Director and Program Assistant and noted that the level of effort percentage certified by the Project Director and Program Assistant and the amount reported in the University?s attestation system were less than the level of effort percentage required in the grant agreement. The hours worked amounted to 27.98% and 20.83%, respectively. However, we noted that the salaries charged to the grant were commensurate with the actual effort reported by the Project Director and the Program Assistant and did not exceed the budgeted amounts in the award notification. Total salaries charged to the grants in 2022 was $320,663, of which $16,244 was for the Project Director and $5,000 was for the Program Assistant. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the level of effort requirement was being met. Cause: Due to turnover at the University, the Project Director and Program Assistant were required to work on other projects. The University did not notify the granting agency in the change in the level of effort for these employees. As the salaries charged to the grants and requested for reimbursement in 2022 was commensurate with the actual level of effort reimbursed for, there are no questioned costs. Effect: The Project Director?s and Program Assistant?s level of effort on the grant is significantly below what was reported in the grant application. However, the salaries charged to the grant and requested for reimbursement are commensurate with the actual level of effort reimbursed for. Questioned Costs: None Recommendation: The University should review its policies and procedures to communicate changes in level of effort to the granting agency in a timely manner and maintain documentation regarding the notification and any subsequent correspondence from the granting agency.
2022-001 ? Level of Effort U.S. Department of Education: Passed through State of New Jersey, Department of Education: Higher Education Institutional Aid - Proyecto Stem: Evidence-Based Approaches to STEM Enrollment, Retention, and Graduation at Urban Public Hispanic-Serving Institution (ALN 84.031C) Federal Award Numbers and Years: P031C160155 (7/1/2021 ? 6/30/2022) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: None Finding Type: Significant Deficiency and Noncompliance Criteria: The specific requirements for matching, level of effort, and earmarking are unique to each Federal program and are found in the statutes, regulations, and the terms and conditions of awards pertaining to the program. Level of effort includes requirements for (a) a specified level of service to be provide from period to period, (b) a specified level of expenditures from non-Federal or Federal sources for specified activities to be maintained from period to period, and (c) Federal funds to supplement and not supplant non-Federal funding of services. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The grant as the following level of effort requirements for key personnel in the award notification letter: We tested the level of effort requirement for the Project Director and Program Assistant and noted that the level of effort percentage certified by the Project Director and Program Assistant and the amount reported in the University?s attestation system were less than the level of effort percentage required in the grant agreement. The hours worked amounted to 27.98% and 20.83%, respectively. However, we noted that the salaries charged to the grant were commensurate with the actual effort reported by the Project Director and the Program Assistant and did not exceed the budgeted amounts in the award notification. Total salaries charged to the grants in 2022 was $320,663, of which $16,244 was for the Project Director and $5,000 was for the Program Assistant. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the level of effort requirement was being met. Cause: Due to turnover at the University, the Project Director and Program Assistant were required to work on other projects. The University did not notify the granting agency in the change in the level of effort for these employees. As the salaries charged to the grants and requested for reimbursement in 2022 was commensurate with the actual level of effort reimbursed for, there are no questioned costs. Effect: The Project Director?s and Program Assistant?s level of effort on the grant is significantly below what was reported in the grant application. However, the salaries charged to the grant and requested for reimbursement are commensurate with the actual level of effort reimbursed for. Questioned Costs: None Recommendation: The University should review its policies and procedures to communicate changes in level of effort to the granting agency in a timely manner and maintain documentation regarding the notification and any subsequent correspondence from the granting agency.
2022 004 Reporting U.S. Department of Education: Student Financial Assistance Cluster ? Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Award Numbers and Years: P063P211813 (7/1/21 ? 6/30/22) and P268K221813 (7/1/21 ? 6/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: N/A Finding Type: Material Weakness Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the 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 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED 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. 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, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that the Pell reporting requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University has a process in place to submit the required information to COD on a weekly basis. For the 40 selections we tested, there were no compliance exceptions noted. However, the University did not properly maintain evidence that they had a control in place to review the ED acknowledgement reports and to ensure disbursement data was reported within the 15 calendar day requirement. The University?s policies and procedures to ensure compliance with the above requirements did not include procedures to properly maintain for the existence of a control or that the control was being performed. Cause The University did not have a process in place to maintain the documentation regarding the existence or performance of the control. Effect The University does not meet the Federal requirements to maintain documentation of its internal controls over the 15 calendar day reporting compliance requirement. Questioned Costs None Recommendation We recommend the University ensure that internal controls are in place surrounding the 15 calendar day reporting process related to Pell and Direct Loan reporting in relation to the Student Financial Assistance Cluster and are performed as designed and documentation is maintained.
2022 004 Reporting U.S. Department of Education: Student Financial Assistance Cluster ? Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Award Numbers and Years: P063P211813 (7/1/21 ? 6/30/22) and P268K221813 (7/1/21 ? 6/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: N/A Finding Type: Material Weakness Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the 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 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED 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. 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, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that the Pell reporting requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University has a process in place to submit the required information to COD on a weekly basis. For the 40 selections we tested, there were no compliance exceptions noted. However, the University did not properly maintain evidence that they had a control in place to review the ED acknowledgement reports and to ensure disbursement data was reported within the 15 calendar day requirement. The University?s policies and procedures to ensure compliance with the above requirements did not include procedures to properly maintain for the existence of a control or that the control was being performed. Cause The University did not have a process in place to maintain the documentation regarding the existence or performance of the control. Effect The University does not meet the Federal requirements to maintain documentation of its internal controls over the 15 calendar day reporting compliance requirement. Questioned Costs None Recommendation We recommend the University ensure that internal controls are in place surrounding the 15 calendar day reporting process related to Pell and Direct Loan reporting in relation to the Student Financial Assistance Cluster and are performed as designed and documentation is maintained.
2022 002 Reporting U.S. Department of Education: Education Stabilization Fund ? Higher Education Emergency Relief Fund (HEERF) Student Aid Portion (ALN 84.425E) Federal Award Numbers and Years: P425F200214 (4/21/20 ? 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2021-003 Finding Type: Material Weakness and Material Noncompliance Criteria The Department of Education requires that institutions who received the Section 18004(a)(1) Student Aid Portion of higher education emergency relief funding (HEERF) to publicly post certain information on their website every calendar quarter. The report must be updated no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context During 2022, the University did not update their website each quarter. The University only updated its website for the quarter ending June 30, 2022. In addition, the University could not provide evidence that the information for the quarter ended June 30, 2022 was updated on the website timely or appropriately reviewed prior to posting. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that information displayed on the website was reported timely, complete and accurate. Cause The University did not have policies and procedures in place to ensure that the website was appropriately updated on a quarterly basis. In addition, the University did not maintain documentation that the information was reported timely and was properly reviewed by someone other than the preparer with knowledge of the subject matter. Effect The information displayed on the University?s website was not current throughout fiscal year 2022. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies and procedures over the website reporting in relation to the Education Stabilization Fund program. We also recommend that the University ensure that internal controls in place surrounding the review of the website reporting are performed as designed and that documentation supporting the amounts reported is adequately maintained, along with evidence that the information was adequately reviewed by someone other than the preparer with knowledge of the subject matter.
2022 003 Cash Management U.S. Department of Education: Education Stabilization Fund ? Higher Education Emergency Relief Fund (HEERF) Minority Serving Institutions (ALN 84.425L) Federal Award Numbers and Years: P425L200021 (4/21/20 ? 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: N/A Finding Type: Material Weakness and Material Noncompliance Criteria For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that cash management requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University had one HEERF drawdown during fiscal year 2022. The drawdown occurred on August 5, 2021, however, the funds were spent during the timeframe of September 23, 2021 through February 10, 2022. Therefore, the University did not spend the drawdown within the required timeframe. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the drawn down funds were spent within the applicable guidelines. Cause The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that funds were spent timely in accordance with the compliance requirement. Effect The University held onto unspent HEERF funds outside of the allowable timeframe, and may have earned unallowable interest on its bank account that should be returned to the awarding agency. Questioned Costs As amounts were ultimately expended for allowable purposes, questioned costs would be limited to interest earned on amounts held outside the allowable timeframe. Recommendation We recommend that the University strengthen its policies and procedures over the cash management process in relation to the Education Stabilization Fund program. We also recommend that the University ensure that internal controls in place surrounding the cash management process are performed as designed.
2022-001 ? Level of Effort U.S. Department of Education: Passed through State of New Jersey, Department of Education: Higher Education Institutional Aid - Proyecto Stem: Evidence-Based Approaches to STEM Enrollment, Retention, and Graduation at Urban Public Hispanic-Serving Institution (ALN 84.031C) Federal Award Numbers and Years: P031C160155 (7/1/2021 ? 6/30/2022) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: None Finding Type: Significant Deficiency and Noncompliance Criteria: The specific requirements for matching, level of effort, and earmarking are unique to each Federal program and are found in the statutes, regulations, and the terms and conditions of awards pertaining to the program. Level of effort includes requirements for (a) a specified level of service to be provide from period to period, (b) a specified level of expenditures from non-Federal or Federal sources for specified activities to be maintained from period to period, and (c) Federal funds to supplement and not supplant non-Federal funding of services. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The grant as the following level of effort requirements for key personnel in the award notification letter: We tested the level of effort requirement for the Project Director and Program Assistant and noted that the level of effort percentage certified by the Project Director and Program Assistant and the amount reported in the University?s attestation system were less than the level of effort percentage required in the grant agreement. The hours worked amounted to 27.98% and 20.83%, respectively. However, we noted that the salaries charged to the grant were commensurate with the actual effort reported by the Project Director and the Program Assistant and did not exceed the budgeted amounts in the award notification. Total salaries charged to the grants in 2022 was $320,663, of which $16,244 was for the Project Director and $5,000 was for the Program Assistant. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the level of effort requirement was being met. Cause: Due to turnover at the University, the Project Director and Program Assistant were required to work on other projects. The University did not notify the granting agency in the change in the level of effort for these employees. As the salaries charged to the grants and requested for reimbursement in 2022 was commensurate with the actual level of effort reimbursed for, there are no questioned costs. Effect: The Project Director?s and Program Assistant?s level of effort on the grant is significantly below what was reported in the grant application. However, the salaries charged to the grant and requested for reimbursement are commensurate with the actual level of effort reimbursed for. Questioned Costs: None Recommendation: The University should review its policies and procedures to communicate changes in level of effort to the granting agency in a timely manner and maintain documentation regarding the notification and any subsequent correspondence from the granting agency.
2022-001 ? Level of Effort U.S. Department of Education: Passed through State of New Jersey, Department of Education: Higher Education Institutional Aid - Proyecto Stem: Evidence-Based Approaches to STEM Enrollment, Retention, and Graduation at Urban Public Hispanic-Serving Institution (ALN 84.031C) Federal Award Numbers and Years: P031C160155 (7/1/2021 ? 6/30/2022) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: None Finding Type: Significant Deficiency and Noncompliance Criteria: The specific requirements for matching, level of effort, and earmarking are unique to each Federal program and are found in the statutes, regulations, and the terms and conditions of awards pertaining to the program. Level of effort includes requirements for (a) a specified level of service to be provide from period to period, (b) a specified level of expenditures from non-Federal or Federal sources for specified activities to be maintained from period to period, and (c) Federal funds to supplement and not supplant non-Federal funding of services. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The grant as the following level of effort requirements for key personnel in the award notification letter: We tested the level of effort requirement for the Project Director and Program Assistant and noted that the level of effort percentage certified by the Project Director and Program Assistant and the amount reported in the University?s attestation system were less than the level of effort percentage required in the grant agreement. The hours worked amounted to 27.98% and 20.83%, respectively. However, we noted that the salaries charged to the grant were commensurate with the actual effort reported by the Project Director and the Program Assistant and did not exceed the budgeted amounts in the award notification. Total salaries charged to the grants in 2022 was $320,663, of which $16,244 was for the Project Director and $5,000 was for the Program Assistant. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the level of effort requirement was being met. Cause: Due to turnover at the University, the Project Director and Program Assistant were required to work on other projects. The University did not notify the granting agency in the change in the level of effort for these employees. As the salaries charged to the grants and requested for reimbursement in 2022 was commensurate with the actual level of effort reimbursed for, there are no questioned costs. Effect: The Project Director?s and Program Assistant?s level of effort on the grant is significantly below what was reported in the grant application. However, the salaries charged to the grant and requested for reimbursement are commensurate with the actual level of effort reimbursed for. Questioned Costs: None Recommendation: The University should review its policies and procedures to communicate changes in level of effort to the granting agency in a timely manner and maintain documentation regarding the notification and any subsequent correspondence from the granting agency.