Criteria: The Code of Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19 require institutes review, update, and certify student enrollment reporting roster on timely and accurate basis at both the campus and program level. Enrollment roster should be certified every 60 days or every other month.
Condition and Context: We reviewed 6 in-scope campuses and a sample of 40 students who graduated, withdrew, or had a change in enrollment during the fiscal year. Of the 40 students tested, 6 students’ enrollment were not certified within the required 60 days period.
Cause and Effect: The campus experienced major personnel changes in the registrar office and did not have adequate staffing in place to monitor the required procedures.
Criteria: The Code of Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19 require institutes review, update, and certify student enrollment reporting roster on timely and accurate basis at both the campus and program level. Enrollment roster should be certified every 60 days or every other month.
Condition and Context: We reviewed 6 in-scope campuses and a sample of 40 students who graduated, withdrew, or had a change in enrollment during the fiscal year. Of the 40 students tested, 6 students’ enrollment were not certified within the required 60 days period.
Cause and Effect: The campus experienced major personnel changes in the registrar office and did not have adequate staffing in place to monitor the required procedures.
Criteria: The Code of Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19 require institutes review, update, and certify student enrollment reporting roster on timely and accurate basis at both the campus and program level. Enrollment roster should be certified every 60 days or every other month.
Condition and Context: We reviewed 6 in-scope campuses and a sample of 40 students who graduated, withdrew, or had a change in enrollment during the fiscal year. Of the 40 students tested, 6 students’ enrollment were not certified within the required 60 days period.
Cause and Effect: The campus experienced major personnel changes in the registrar office and did not have adequate staffing in place to monitor the required procedures.
Criteria: The Code of Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19 require institutes review, update, and certify student enrollment reporting roster on timely and accurate basis at both the campus and program level. Enrollment roster should be certified every 60 days or every other month.
Condition and Context: We reviewed 6 in-scope campuses and a sample of 40 students who graduated, withdrew, or had a change in enrollment during the fiscal year. Of the 40 students tested, 6 students’ enrollment were not certified within the required 60 days period.
Cause and Effect: The campus experienced major personnel changes in the registrar office and did not have adequate staffing in place to monitor the required procedures.
Criteria: According to 86 FR 26213 (Document Number: 2021-10196), the quarterly report must appear in a format and location that is easily accessible to the public. The information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition and Context: During the single audit, two reports were untimely reported in accordance with the HEERF reporting requirements. CSU San Bernardino failed to report the required information within the 10 days required period for the quarters ending December 31, 2022 and June 30, 2023; information on the student reports was accurate but not reported on a timely basis, per the requirement.
Cause and Effect: Management failed to report in a timely manner.
Criteria: According to 86 FR 26213 (Document Number: 2021-10196), the quarterly report must appear in a format and location that is easily accessible to the public. The information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition and Context: During the single audit, two reports were untimely reported in accordance with the HEERF reporting requirements. CSU San Bernardino failed to report the required information within the 10 days required period for the quarters ending December 31, 2022 and June 30, 2023; information on the student reports was accurate but not reported on a timely basis, per the requirement.
Cause and Effect: Management failed to report in a timely manner.
Criteria: According to 86 FR 26213 (Document Number: 2021-10196), the quarterly report must appear in a format and location that is easily accessible to the public. The information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition and Context: During the single audit, two reports were untimely reported in accordance with the HEERF reporting requirements. CSU San Bernardino failed to report the required information within the 10 days required period for the quarters ending December 31, 2022 and June 30, 2023; information on the student reports was accurate but not reported on a timely basis, per the requirement.
Cause and Effect: Management failed to report in a timely manner.
Criteria: According to 86 FR 26213 (Document Number: 2021-10196), the quarterly report must appear in a format and location that is easily accessible to the public. The information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition and Context: During the single audit, two reports were untimely reported in accordance with the HEERF reporting requirements. CSU San Bernardino failed to report the required information within the 10 days required period for the quarters ending December 31, 2022 and June 30, 2023; information on the student reports was accurate but not reported on a timely basis, per the requirement.
Cause and Effect: Management failed to report in a timely manner.
Criteria: According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the entity’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.
Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designated to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately and completely reported on the SEFA.
Condition and Context: Confition and Context: The University did not have adequate controls relating to the reporting of expenditures on the SEFA for the Supplemental Nutrition Assistance Program Cluster (SNAP). Both the College of Continuing Education (CCE) and the Population Research Center (PRC) which is part of the Sacramento campus incurred SNAP expenditures that were not reported on the fiscal year 2023 SEFA. The SNAP agreement was entered into between the California Department of Social Services and California State University-Sacramento on behalf of CCE. PRC was listed as a sub awardee within the SNAP agreement.
Written policies and procedures require each unit/department within the Sacramento campus to send all external grants and contracts to the Sacramento campus Office of Research, Innovation and Economic Development (ORIED). ORIED performs a review of each applicable
agreement received to determine that separate general ledger accounts have been established and whether the funding source has been accurately identified in the general ledger (i.e. federal). The CCE did not send the SNAP contract to ORIED and as a result, the review control did not operate as designed. Separate accounts, to track federal funding, were not established in the general ledger and instead, SNAP activity was accounted for within the tuition and fees general ledger accounts which resulted in SNAP activity being managed via manual spreadsheets. While performing budget control reviews during the year ended June 30, 2024, the CCE determined that certain SNAP expenditures had not been reported on the fiscal year 2023 SEFA. The University’s overall SEFA is compiled by the Chancellor’s office and relies on each campus to have internal controls that ensure completeness and accuracy of the SEFA.
Cause & Effect: In discussing these conditions with the University, they stated the error was primarily due to significant turnover during fiscal year 2023 in the CCE and as a result the required policies and procedures for identifying, tracking, and communicating federal expenditures were not adhered to. Additionally, management review controls at the campus over the completeness and accuracy of the SEFA were not designed to detect the error.
Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the University from completing an audit in accordance with the timelines of Uniform Guidance.
Criteria: In accordance with 2 CFR 200 Subpart E, the University is required to conform to allowability of cost provisions, and 2 CFR 200.303 requires the organization to establish and maintain effective controls over federal awards. Allowable costs charged to federal programs, whether direct or indirect, must be allowable and be determined in accordance with Subpart E – Cost Principles of the Uniform Guidance. Effective internal controls should include procedures to ensure federal expenditures and amounts are for activities allowed or unallowed and allowable costs/cost principles, as well as accurately and completely reported on the SEFA.
According to 2 CFR 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the recipient or subrecipient;
(iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy;
(v) Comply with the established accounting policies and procedures of the recipient or subrecipient and
(vi) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Condition and Context: The University receives Supplemental Nutrition Assistance Program (SNAP) Cluster program funding at its Sacramento campus to perform nutrition outreach and education services to residents of the State of California. The Sacramento campus administers the SNAP Cluster nutrition education programs through its College of Continuing Education (CCE) and Population Research Center (PRC) offices. SNAP Cluster program expenditures are primarily comprised of payroll for program personnel performing various program activities and
related fringe benefits and indirect costs.
During our testing of 18 payroll expenditures for CCE employees (totaling $90,946) and 40 payroll expenditures for PRC employees (totaling $66,458), we noted effort reports detailing 100% of the employee's activities were not prepared for certain employees. Upon further
investigation and discussion with CCE and PRC program management, we noted effort reports were not prepared for any employees whose payroll expenditures were charged to the SNAP Cluster program, except for student workers who solely worked on SNAP Cluster program
activities.
The payroll expenditures and related costs impacted by the inadequate
effort reports, are described in the table below:
Expenditure category Questioned costs Excerpt of total SNAP Cluster program expenditures by impacted expenditure category
Payroll $1,151,941 $1,354,046
Fringe benefits $641,501 $641,501
Indirect costs $448,286 $660,709
Total $2,241,728 $2,656,257
Total SNAP Cluster program expenditures were $3,688,927 for the year ended June 30, 2023.
We noted additional instances of noncompliance as follows:
• In our testing of 58 payroll expenditures, the hourly payroll rates used to prepare the quarterly payroll remittances submitted to the State of California exceeded the actual payroll rates paid for 15 employees resulting in an overcharge of payroll, fringe benefits, and indirect costs to the SNAP program of $11,710, $9,684, and $5,348, respectively. As these 15 employees did not have effort reports as discussed above, payroll, fringe benefits, and indirect costs associated with these 15 employees has already been included in the table above.
• One individually significant payroll expenditure that was associated with one employee was double counted in the quarterly State of California remittance billing resulting in an overcharge to the SNAP Cluster program of $27,004, $10,801, and $9,451, respectively. As the employee did not have an effort report as discussed above, payroll, fringe benefits, and indirect costs associated with this employee has already been included in the table above.
• In our testing of 7 indirect cost charges, we identified 4 indirect cost charges that utilized higher than the allowed hourly rates within the calculation. These 4 indirect cost charges related to CCE employees in which the hourly rate listed in the program agreement was billed versus the employee’s actual hourly pay rate and fringe benefit costs. As a result, the total payroll charges used to bill the indirect cost rate of 25% utilized unallowable payroll expenditures, which resulted in the SNAP Cluster program being overcharged by $46,922. As these employees also did not have effort reports as discussed above, payroll, fringe benefits, and indirect costs associated with these CCE employees has already been included in the table above.
In addition, we noted the Sacramento campus has not established adequate internal controls to ensure: (1) payroll expenditures charged to the SNAP Cluster program are properly determined and supported in accordance with the requirements of the Uniform Guidance and (2) fringe
benefit and indirect costs are properly calculated by applying the approved fringe or indirect cost rate to a base that includes only allowable costs.
Cause & Effect: The errors noted above were primarily due to insufficient controls over the establishment and tracking of SNAP Cluster program activities as federal funding within Sacramento’s general ledger. As a result, a portion of SNAP program expenditures and activities were not processed in accordance with applicable federal guidelines. Additional errors noted above relate to insufficient controls over the accuracy of the payroll, fringe benefits, and indirect cost charged to the SNAP Cluster program. The inadequate review procedures over payroll, fringe benefits, and indirect cost expenditures resulted in unallowable charges to the SNAP Cluster program in the amount of $2,241,728.
Criteria: The Code of Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19 require institutes review, update, and certify student enrollment reporting roster on timely and accurate basis at both the campus and program level. Enrollment roster should be certified every 60 days or every other month.
Condition and Context: We reviewed 6 in-scope campuses and a sample of 40 students who graduated, withdrew, or had a change in enrollment during the fiscal year. Of the 40 students tested, 6 students’ enrollment were not certified within the required 60 days period.
Cause and Effect: The campus experienced major personnel changes in the registrar office and did not have adequate staffing in place to monitor the required procedures.
Criteria: The Code of Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19 require institutes review, update, and certify student enrollment reporting roster on timely and accurate basis at both the campus and program level. Enrollment roster should be certified every 60 days or every other month.
Condition and Context: We reviewed 6 in-scope campuses and a sample of 40 students who graduated, withdrew, or had a change in enrollment during the fiscal year. Of the 40 students tested, 6 students’ enrollment were not certified within the required 60 days period.
Cause and Effect: The campus experienced major personnel changes in the registrar office and did not have adequate staffing in place to monitor the required procedures.
Criteria: The Code of Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19 require institutes review, update, and certify student enrollment reporting roster on timely and accurate basis at both the campus and program level. Enrollment roster should be certified every 60 days or every other month.
Condition and Context: We reviewed 6 in-scope campuses and a sample of 40 students who graduated, withdrew, or had a change in enrollment during the fiscal year. Of the 40 students tested, 6 students’ enrollment were not certified within the required 60 days period.
Cause and Effect: The campus experienced major personnel changes in the registrar office and did not have adequate staffing in place to monitor the required procedures.
Criteria: The Code of Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19 require institutes review, update, and certify student enrollment reporting roster on timely and accurate basis at both the campus and program level. Enrollment roster should be certified every 60 days or every other month.
Condition and Context: We reviewed 6 in-scope campuses and a sample of 40 students who graduated, withdrew, or had a change in enrollment during the fiscal year. Of the 40 students tested, 6 students’ enrollment were not certified within the required 60 days period.
Cause and Effect: The campus experienced major personnel changes in the registrar office and did not have adequate staffing in place to monitor the required procedures.
Criteria: According to 86 FR 26213 (Document Number: 2021-10196), the quarterly report must appear in a format and location that is easily accessible to the public. The information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition and Context: During the single audit, two reports were untimely reported in accordance with the HEERF reporting requirements. CSU San Bernardino failed to report the required information within the 10 days required period for the quarters ending December 31, 2022 and June 30, 2023; information on the student reports was accurate but not reported on a timely basis, per the requirement.
Cause and Effect: Management failed to report in a timely manner.
Criteria: According to 86 FR 26213 (Document Number: 2021-10196), the quarterly report must appear in a format and location that is easily accessible to the public. The information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition and Context: During the single audit, two reports were untimely reported in accordance with the HEERF reporting requirements. CSU San Bernardino failed to report the required information within the 10 days required period for the quarters ending December 31, 2022 and June 30, 2023; information on the student reports was accurate but not reported on a timely basis, per the requirement.
Cause and Effect: Management failed to report in a timely manner.
Criteria: According to 86 FR 26213 (Document Number: 2021-10196), the quarterly report must appear in a format and location that is easily accessible to the public. The information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition and Context: During the single audit, two reports were untimely reported in accordance with the HEERF reporting requirements. CSU San Bernardino failed to report the required information within the 10 days required period for the quarters ending December 31, 2022 and June 30, 2023; information on the student reports was accurate but not reported on a timely basis, per the requirement.
Cause and Effect: Management failed to report in a timely manner.
Criteria: According to 86 FR 26213 (Document Number: 2021-10196), the quarterly report must appear in a format and location that is easily accessible to the public. The information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition and Context: During the single audit, two reports were untimely reported in accordance with the HEERF reporting requirements. CSU San Bernardino failed to report the required information within the 10 days required period for the quarters ending December 31, 2022 and June 30, 2023; information on the student reports was accurate but not reported on a timely basis, per the requirement.
Cause and Effect: Management failed to report in a timely manner.
Criteria: According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the entity’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.
Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designated to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately and completely reported on the SEFA.
Condition and Context: Confition and Context: The University did not have adequate controls relating to the reporting of expenditures on the SEFA for the Supplemental Nutrition Assistance Program Cluster (SNAP). Both the College of Continuing Education (CCE) and the Population Research Center (PRC) which is part of the Sacramento campus incurred SNAP expenditures that were not reported on the fiscal year 2023 SEFA. The SNAP agreement was entered into between the California Department of Social Services and California State University-Sacramento on behalf of CCE. PRC was listed as a sub awardee within the SNAP agreement.
Written policies and procedures require each unit/department within the Sacramento campus to send all external grants and contracts to the Sacramento campus Office of Research, Innovation and Economic Development (ORIED). ORIED performs a review of each applicable
agreement received to determine that separate general ledger accounts have been established and whether the funding source has been accurately identified in the general ledger (i.e. federal). The CCE did not send the SNAP contract to ORIED and as a result, the review control did not operate as designed. Separate accounts, to track federal funding, were not established in the general ledger and instead, SNAP activity was accounted for within the tuition and fees general ledger accounts which resulted in SNAP activity being managed via manual spreadsheets. While performing budget control reviews during the year ended June 30, 2024, the CCE determined that certain SNAP expenditures had not been reported on the fiscal year 2023 SEFA. The University’s overall SEFA is compiled by the Chancellor’s office and relies on each campus to have internal controls that ensure completeness and accuracy of the SEFA.
Cause & Effect: In discussing these conditions with the University, they stated the error was primarily due to significant turnover during fiscal year 2023 in the CCE and as a result the required policies and procedures for identifying, tracking, and communicating federal expenditures were not adhered to. Additionally, management review controls at the campus over the completeness and accuracy of the SEFA were not designed to detect the error.
Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the University from completing an audit in accordance with the timelines of Uniform Guidance.
Criteria: In accordance with 2 CFR 200 Subpart E, the University is required to conform to allowability of cost provisions, and 2 CFR 200.303 requires the organization to establish and maintain effective controls over federal awards. Allowable costs charged to federal programs, whether direct or indirect, must be allowable and be determined in accordance with Subpart E – Cost Principles of the Uniform Guidance. Effective internal controls should include procedures to ensure federal expenditures and amounts are for activities allowed or unallowed and allowable costs/cost principles, as well as accurately and completely reported on the SEFA.
According to 2 CFR 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the recipient or subrecipient;
(iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy;
(v) Comply with the established accounting policies and procedures of the recipient or subrecipient and
(vi) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Condition and Context: The University receives Supplemental Nutrition Assistance Program (SNAP) Cluster program funding at its Sacramento campus to perform nutrition outreach and education services to residents of the State of California. The Sacramento campus administers the SNAP Cluster nutrition education programs through its College of Continuing Education (CCE) and Population Research Center (PRC) offices. SNAP Cluster program expenditures are primarily comprised of payroll for program personnel performing various program activities and
related fringe benefits and indirect costs.
During our testing of 18 payroll expenditures for CCE employees (totaling $90,946) and 40 payroll expenditures for PRC employees (totaling $66,458), we noted effort reports detailing 100% of the employee's activities were not prepared for certain employees. Upon further
investigation and discussion with CCE and PRC program management, we noted effort reports were not prepared for any employees whose payroll expenditures were charged to the SNAP Cluster program, except for student workers who solely worked on SNAP Cluster program
activities.
The payroll expenditures and related costs impacted by the inadequate
effort reports, are described in the table below:
Expenditure category Questioned costs Excerpt of total SNAP Cluster program expenditures by impacted expenditure category
Payroll $1,151,941 $1,354,046
Fringe benefits $641,501 $641,501
Indirect costs $448,286 $660,709
Total $2,241,728 $2,656,257
Total SNAP Cluster program expenditures were $3,688,927 for the year ended June 30, 2023.
We noted additional instances of noncompliance as follows:
• In our testing of 58 payroll expenditures, the hourly payroll rates used to prepare the quarterly payroll remittances submitted to the State of California exceeded the actual payroll rates paid for 15 employees resulting in an overcharge of payroll, fringe benefits, and indirect costs to the SNAP program of $11,710, $9,684, and $5,348, respectively. As these 15 employees did not have effort reports as discussed above, payroll, fringe benefits, and indirect costs associated with these 15 employees has already been included in the table above.
• One individually significant payroll expenditure that was associated with one employee was double counted in the quarterly State of California remittance billing resulting in an overcharge to the SNAP Cluster program of $27,004, $10,801, and $9,451, respectively. As the employee did not have an effort report as discussed above, payroll, fringe benefits, and indirect costs associated with this employee has already been included in the table above.
• In our testing of 7 indirect cost charges, we identified 4 indirect cost charges that utilized higher than the allowed hourly rates within the calculation. These 4 indirect cost charges related to CCE employees in which the hourly rate listed in the program agreement was billed versus the employee’s actual hourly pay rate and fringe benefit costs. As a result, the total payroll charges used to bill the indirect cost rate of 25% utilized unallowable payroll expenditures, which resulted in the SNAP Cluster program being overcharged by $46,922. As these employees also did not have effort reports as discussed above, payroll, fringe benefits, and indirect costs associated with these CCE employees has already been included in the table above.
In addition, we noted the Sacramento campus has not established adequate internal controls to ensure: (1) payroll expenditures charged to the SNAP Cluster program are properly determined and supported in accordance with the requirements of the Uniform Guidance and (2) fringe
benefit and indirect costs are properly calculated by applying the approved fringe or indirect cost rate to a base that includes only allowable costs.
Cause & Effect: The errors noted above were primarily due to insufficient controls over the establishment and tracking of SNAP Cluster program activities as federal funding within Sacramento’s general ledger. As a result, a portion of SNAP program expenditures and activities were not processed in accordance with applicable federal guidelines. Additional errors noted above relate to insufficient controls over the accuracy of the payroll, fringe benefits, and indirect cost charged to the SNAP Cluster program. The inadequate review procedures over payroll, fringe benefits, and indirect cost expenditures resulted in unallowable charges to the SNAP Cluster program in the amount of $2,241,728.